Treasury Releases Informational Licensing Guidance for Humanitarian NGOs

October 17, 2014

On Oct. 17, 2014 the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) released a document titled Guidance Related to the Provision of Humanitarian Assistance by Not for Profit Non-Governmental Organizations.

The two-page document provides some clarification of the status quo without making substantive changes called for by the nonprofit sector or committing to specific actions OFAC may take to address systemic problems with its licensing system. It does not address the problems the State Department's involvement in licensing creates, including delays and politicization of humanitarian decisions.

In addition, the document clearly states that it is for informational purposes only and does not have the force of law. It does not address the needs of development, peacebuilding, human rights or other types of nonprofit programs abroad.

While clarifications from OFAC are welcome, the overall thrust of the document is to restate existing policies and provide assurances that have no legal force.  The most positive view is that it is a good beginning for a dialog between OFAC, the State Department and the nonprofit sector on the next phase of improvements needed.

For background information see U.S. Civil Society Submission to the UN Human Rights Commission, Sept. 15, 2014, describing human rights problems with the licensing system.

Treasury’s Informational Licensing Guidance for Humanitarian NGOs Falls Short

October 24, 2014

On Oct. 17, 2014 the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) released Guidance Related to the Provision of Humanitarian Assistnace by Not for Profit Non-Governmenal Organizations, intended to provide clarification for nonprofits seeking licenses for activities that would otherwise be prohibited by economic sanctions programs.

New Interactive Map Highlights Humanitarian Crises Where Terror Groups Operate

An interactive map on our website has been completely overhauled and updated. Mapping Listed Terrorist Groups and Humanitarian Crises features a map with links to information on countries where there are both humanitarian crises and terrorist groups listed by the U.S. government. 

Individual country pages include recent background on the crisis, brief summaries of listed terrorist groups operating in that country, and links to recent news articles and other resources. 

Eleven countries are highlighted on the map: Afghanistan, Cameroon, Chad, Iraq, Libya, Mali, Nigeria, Palestine, Somalia, Syria and Yemen. A linkable list of those same countries is provided below the map for ease of use. 

Mapping Listed Terrorist Groups and Humanitarian Crises

August 1, 2016

The U.S. government maintains two lists containing entities (State's Foreign Terrorist Organizations (FTO) & Treasury's Specially Designated Nationals (SDN)) it believes engage in terrorist activity. It is illegal to provide these groups with material support which is defined broadly in the law to include tangible goods like food or clothing, medical services, and training in conflict mediation. 

But the laws designed to starve the terrorists also make it nearly impossible for humanitarian actors to reach or offer assistance to civilians living in territory controlled by a blacklisted group. That means that in conflict zones or natural disaster areas where these groups are active, providing medical services or distributing non-medicinal necessities such as clean water, tents, blankets, food can be prohibited.